1. Introduction

Mockapital is committed to maintaining high standards of Anti Money Laundering (AML) and Counter Terrorism Financing (CTF) compliance. We recognize that as a financial services provider, it is important to detect and prevent money laundering, terrorism financing, sanctions evasion, fraud, and other illegal financial activities. This policy is designed to support Mockapital’s adherence to applicable AML, CTF, sanctions, and related regulatory requirements in the UAE and internationally.

2. Regulatory and Sanctions Compliance

Mockapital is committed to complying with relevant AML regulations and counter terrorism financing laws as set by UAE authorities and international standards. We will adhere to:

UAE AML Laws: Complying with applicable AML laws and regulations as mandated by relevant UAE authorities and local regulatory bodies.
International Standards: Following global guidelines established by organizations such as the Financial Action Task Force (FATF), U.S. OFAC, the United Nations, and the European Union, and ensuring compliance with applicable sanctions lists from these and other bodies.

In addition to these broader regulatory commitments, Mockapital will actively screen customers and transactions against relevant sanctions lists, including UN Sanctions, OFAC, and EU Sanctions, to detect prohibited individuals, entities, jurisdictions, or activities. If a confirmed match is found, Mockapital may freeze, suspend, reject, or restrict the account and report the matter to the relevant authorities where required by law.

3. Customer Due Diligence (CDD)

Mockapital will implement appropriate Customer Due Diligence (CDD) measures to ensure that it understands the nature and purpose of customer relationships. This includes verifying the identity of customers using reliable, independent sources and monitoring customer activity for suspicious patterns.

Know Your Customer (KYC): Mockapital will obtain necessary documentation to verify the identity of clients, including government issued identification, proof of address, and relevant company information where applicable.
Ongoing Monitoring: Mockapital will continuously monitor customer accounts and transactions, particularly focusing on large, unusual, or inconsistent activity that could indicate money laundering, terrorism financing, sanctions exposure, or other financial crime risks.

4. KYC Verification Timing and Control Provider

Mockapital collects basic client information during account registration and account purchase. Full KYC verification is required after a trader successfully completes the evaluation challenge and before access to a Simulated Funded Account is granted.

No trader will be provided access to a Simulated Funded Account until full KYC verification has been completed and approved. Traders who do not complete or pass KYC verification will not be eligible to receive access to a Simulated Funded Account or any related payout.

Mockapital may also request KYC verification or additional supporting documents at an earlier stage if a transaction, payment pattern, jurisdiction, account activity, or other risk indicator raises compliance concerns.

Mockapital uses Veriff as its identity verification and KYC control provider. Veriff supports customer identity verification through document checks and, where applicable, additional verification measures such as liveness checks, sanctions screening, politically exposed person screening, adverse media screening, and other risk based verification controls.

Mockapital may use the results of these checks to approve, reject, suspend, restrict, or further review a customer relationship in accordance with its AML, CTF, sanctions, and risk management obligations.

5. Prohibited Jurisdictions and Citizens

Mockapital does not onboard, serve, or provide accounts to individuals or entities located in, residing in, incorporated in, operating from, or holding citizenship from prohibited jurisdictions.

At a minimum, Mockapital prohibits customers connected to the following jurisdictions and territories:

Iran
North Korea
Myanmar
Russian Federation
Belarus
Crimea
Occupied parts of Donetsk
Occupied parts of Luhansk
Occupied parts of Zaporizhzhia
Occupied parts of Kherson

Mockapital may update this list from time to time in line with applicable sanctions, regulatory requirements, payment partner requirements, and internal risk controls.

Customers from prohibited jurisdictions, or citizens of prohibited jurisdictions, will not be permitted to proceed with Mockapital services. If such a connection is identified after registration, purchase, challenge completion, or during any later review, Mockapital may reject the customer, suspend the account, cancel access, freeze activity, request additional documentation, or take any other action required under applicable law, sanctions obligations, or internal compliance procedures.

6. Enhanced Due Diligence (EDD)

While the majority of our customer base involves relatively small transactions for trading challenges, Mockapital will adopt a risk based approach to compliance. Enhanced Due Diligence (EDD) will be applied selectively based on the following indicators of higher risk:

Customers from high risk jurisdictions.
Customers exhibiting unusual or suspicious behavior.
Politically Exposed Persons (PEPs).
Multiple transactions or attempts to evade normal procedures, such as paying from different sources for the same challenge.
Unusual payment behavior, inconsistent identity information, sanctions exposure, or attempts to conceal location, nationality, ownership, or source of funds.

If any of these risk indicators are detected, Mockapital will conduct a thorough review of the customer relationship and may request additional documentation or clarification to ensure full compliance with AML requirements.

7. Country Risk Matrix

Mockapital maintains a country risk based approach for customer onboarding and monitoring. Countries may be classified as low risk, medium risk, high risk, or prohibited based on sanctions exposure, FATF status, AML and CTF risk, regulatory restrictions, payment partner requirements, and internal business risk considerations.

Customers from high risk jurisdictions may be subject to Enhanced Due Diligence, additional documentation requests, manual compliance review, or rejection where the risk cannot be appropriately managed.

The prohibited jurisdiction list overrides the country risk matrix. Customers linked to prohibited jurisdictions will not be accepted regardless of other risk factors.

8. Record Keeping

Mockapital will retain records of customer identification documents, verification results, transaction records, and relevant correspondence for a minimum of five years, or longer where required by applicable law or regulatory requirements. These records will be kept in a secure and accessible manner for regulatory review and internal audit purposes.

9. Suspicious Activity Reporting (SAR)

Mockapital is committed to adhering to AML regulations and international standards by monitoring and reporting suspicious activities where required.

Monitoring Transactions: Transactions will be reviewed for unusual patterns or large sums, particularly those from high risk jurisdictions or with atypical payment structures.
Reporting Suspicious Activity: In line with the regulatory requirements of our operating free zone, Mockapital will file a Suspicious Activity Report (SAR) with the relevant free zone authority or financial regulator should suspicious activities be detected. We will also comply with international AML standards, including FATF recommendations, regardless of the customer’s nationality or location.
Cooperation with Authorities: Should a SAR be filed, Mockapital will cooperate with relevant authorities and may take appropriate action, such as freezing, suspending, or restricting accounts, to prevent potential illegal activity.

10. Responsibilities of Employees

All employees and contractors of Mockapital are required to adhere to the provisions of this AML policy. Specific responsibilities include:

Compliance Officers: Ensuring the implementation of this policy and overseeing customer due diligence, transaction monitoring, sanctions screening, escalation, and reporting.
Front Line Staff: Responsible for supporting customer verification procedures and remaining vigilant in identifying suspicious behavior, unusual transactions, or risk indicators.
Training and Awareness: Employees will receive AML training regularly to ensure they are aware of the risks associated with money laundering and terrorism financing and the appropriate steps to mitigate these risks.

11. Risk Based Approach

Mockapital will adopt a risk based approach to AML, ensuring that higher risk customers, transactions, jurisdictions, and business relationships receive enhanced scrutiny. We will assess risk based on factors such as:

The customer’s country of origin, residence, citizenship, and operating location.
The customer’s business activity, industry, and profile where applicable.
The transaction size, frequency, source, and pattern.
Any sanctions, PEP, adverse media, or other risk indicators identified during screening or monitoring.

12. Review and Auditing

Mockapital’s AML policy will be reviewed on an annual basis or as required by changes in regulations, sanctions requirements, payment partner requirements, or business practices. Internal audits may be conducted to assess compliance with AML procedures and identify areas for improvement.

13. Conclusion

Mockapital is fully committed to ensuring a robust and compliant environment that helps prevent money laundering, terrorism financing, sanctions evasion, fraud, and other illegal financial activity. By adhering to this policy and working with legal experts, regulatory authorities, compliance providers, and AML professionals, Mockapital aims to protect its business and contribute to the integrity of the financial system.

14. Contact Information

For any further inquiries, please contact our Compliance Team at:

Email: compliance@mockapital.com